Gradient Labs Limited

Company Number 14864752

10 Holmesdale Road, London, N65TQ, United Kingdom

23 July 2023

Website Privacy Policy


1.1 Important information and who we are

Welcome to Gradient Labs Limited’s Privacy and Data Protection Policy (“Privacy Policy”).

At Gradient Labs Limited (“we”, “us”, or “our”) we are committed to protecting and  respecting your privacy and Personal Data in compliance with the United Kingdom General  Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory  laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy  Policy will tell you about your privacy rights, how the law protects you, and inform our  employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include any people that the  organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data  processed at any time by us.

1.2 Your Data Controller

Gradient Labs Limited is your Data Controller and responsible for your Personal Data. We  are not obliged by the GDPR to appoint a data protection officer and have not voluntarily  appointed one at this time. Therefore, any inquiries about your data should either be sent  to us by email to or by post to 10 Holmesdale Road, London,  N65TQ, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s  Office (ICO), the UK supervisory authority for data protection issues ( We

would, however, appreciate the chance to deal with your concerns before you approach  the ICO so please contact us in the first instance.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal  with your data on our behalf (known as “Processors”). The responsibilities below may be  assigned to an individual or may be taken to apply to the organisation as a whole. The  Data Controller and our Processors have the following responsibilities:


2.1 Types of data / Privacy policy scope

Personal Data” means any information about an individual from which that person can  be identified. It does not include data where the identity has been removed (anonymous  data).

We may collect, use, store and transfer different kinds of Personal Data about you which  we have grouped together below. Not all of the following types of data will necessarily be  collected from you but this is the full scope of data that we collect and when we collect it  from you:

We do not collect any Special Categories of Personal Data about you (this includes details  about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,  political opinions, trade union membership, information about your health, and genetic  and biometric data). Nor do we collect any information about criminal convictions and  offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and  processing of Personal Data. The main avenues we rely on are:

Consent”: Certain situations allow us to collect your Personal Data, such as when  you tick a box that confirms you are happy to receive email newsletters from us, or  ‘opt in’ to a service.

Contractual Obligations”: We may require certain information from you in order  to fulfil our contractual obligations and provide you with the promised service.

Legal Compliance”: We’re required by law to collect and process certain types of  data, such as fraudulent activity or other illegal actions.

Legitimate Interest”: We might need to collect certain information from you to be  able to meet our legitimate interests - this covers aspects that can be reasonably  expected as part of running our business, that will not have a material impact on  your rights, freedom or interests. Examples could be your address, so that we know  where to deliver something to, or your name, so that we have a record of who to  contact moving forwards.


3.1 Our data uses

We will only use your Personal Data when the law allows us to.

Set out below is a table containing the different types of Personal Data we collect and the  lawful basis for processing that data. Please refer to section 2.2 for more information on  the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which  we use your data may be broader than described but we will never process your data  without a legal basis for doing so and it is for a related purpose. For further inquiries  please contact us.


Type of data



Lawful basis  

for processing  data

When you browse our website  we process your IP address,  Google Analytics ID, internet  browser and device type,  

location data and your use of  the website, including which  pages you visited, how you  got to our website, and the  time and length of your visit.

Other Data



We need to  make sure our  website works  properly, including debugging, to  be able to  deliver you  content and for DDOS  mitigation on  

our website,  and improving  our website  and to perform  statistical  

analyses for optimizing our website.

You can use our website to  contact us or to request us to  contact you.



Contact Data


We need to use that data  to be able to  

reach out to  you based on  your request.

You can subscribe to our  

newsletter or get invitations  to events by providing your  name and email address  

through the sign-up form on  our website.



Contact Data

Marketing and  

Communications  Data


When you fill out the  

newsletter signup form  you indicate  

your consent to receive messages from  us.

We use cookies and similar techniques, such as tags/beacons and javascripts, which are small text files stored on your device.

Usage Data

Other Data

Legitimate Interest

We use cookies to continuously enhance our website, cater to your needs, and optimise our marketing approach. To achieve this, we deploy functional cookies to ensure the website operates properly, and marketing cookies to help us reach the appropriate audience and display relevant advertisements.

When a website visitor chats to our customer support via email or chat

Profile/Identity Data

Contact Data

Customer Support Data


We need to store the data to be able to provide a response or a chat/email follow up to users

3.2 Marketing and content updates

You will receive marketing and new content communications from us if you have created  an account and chosen to opt into receiving those communications. From time to time we  may make suggestions and recommendations to you about goods or services that may be  of interest to you.

3.3 Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we  reasonably consider that we need to use it for another reason and that reason is  compatible with the original purpose. If you wish to get an explanation as to how the  processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we  will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent,  in compliance with the above rules, where this is required or permitted by law.


4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in  relation to your personal data:

Right to be informed. You have a right to be informed about our purposes for  processing your personal data, how long we store it for, and who it will be shared  with. We have provided this information to you in this policy.

Right of access. This enables you to receive a copy of the personal data we hold  about you and to check that we are lawfully processing it (also known as a "data  subject access request"). See section 4.4 below for more details on how you can  make a data subject access request.

Right to rectification. You have a right to request correction of the personal data  that we hold about you. This enables you to have any incomplete or inaccurate data  we hold about you corrected, though we may need to verify the accuracy of the new  data you provide to us.

Right to erasure. You have the right to ask us to delete or remove personal data  where there is no good reason for us continuing to process it, where you have  successfully exercised your right to object to processing (see below), where we may  have processed your information unlawfully or where we are required to erase your  personal data to comply with local law. Note, however, that we may not always be  able to comply with your request of erasure for specific legal reasons which will be  notified to you, if applicable, at the time of your request.

Right to object. You can object to the processing of personal data we hold about  you. This effectively allows you to stop or prevent us from processing your personal  data. Note that this is not an absolute right and it only applies in certain  circumstances, for example:

(i) Where we are processing your personal data for direct marketing purposes.

(ii) Where we are relying on a legitimate interest (or those of a third party) and  there is something about your particular situation which makes you want to  object to processing on this ground as you feel it impacts on your  fundamental rights and freedoms.

(iii) In some cases, we may continue processing your data if we can demonstrate  that we have compelling legitimate grounds to process your information  which override your rights and freedoms.

Right to restrict processing. You have the right to request the restriction or  suppression of their personal data. Note that this is not an absolute right and it only  applies in certain circumstances:

(i) If you want us to establish the data's accuracy.

(ii) Where our use of the data is unlawful but you do not want us to erase it.

(iii) Where you need us to hold the data even if we no longer require it as you  need it to establish, exercise or defend legal claims.

(iv) You have objected to our use of your data but we need to verify whether we  have overriding legitimate grounds to use it.

Right to data portability. You have the right to request the transfer of your  personal data to you or to a third party. If you make such a request, we will provide  to you, or a third party you have chosen, your personal data in a structured,  commonly used, machine-readable format. Note that this right only applies to  automated information which you initially provided consent for us to use or where  we used the information to perform a contract with you.

If you wish to make a request under any of these rights, please contact us at

4.2 How Gradient Labs Limited protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate  disclosure. We implement a variety of security measures to ensure the security of your  Personal Data on our systems, including data encryption, role based access controls, data  access reviews, real-time security compliance monitoring and more. Any Personal Data  collected by us is only accessible by a limited number of employees who have special  access rights to such systems and are bound by obligations of confidentiality. If and when  we use subcontractors to store your data, we will not relinquish control of your Personal  Data or expose it to security risks that would not have arisen had the data remained in our  possession. However, unfortunately no transmission of data over the internet is  guaranteed to be completely secure. It may be possible for third parties not under the  control of Gradient Labs Limited to intercept or access transmissions or private  communications unlawfully. While we strive to protect your Personal Data, we cannot  ensure or warrant the security of any Personal Data you transmit to us. Any such  transmission is done at your own risk. If you believe that your interaction with us is no  longer secure, please contact us.

4.3 Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by You can at any  time unsubscribe from receiving marketing emails by following the instructions provided  in any of the newsletters..

Where you opt out of receiving these marketing messages, we will continue to retain other  Personal Data provided to us as a result of interactions with us not related to your  marketing preferences.

4.4 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other  rights). However, if your request is clearly unfounded, we could refuse to comply with your  request.

We may need to request specific information from you to help us confirm your identity  and ensure you have the right to access your Personal Data (or to exercise any of your  other rights). This is a security measure to ensure that Personal Data is not disclosed to  

any person who has no right to receive it. We may also contact you to ask you for further  information in relation to your request to speed up our response.


5.1 Sharing your data with third parties

We may share non-Personal Data with third parties. We may share your Personal Data  with subcontractors or affiliates, subject to confidentiality obligations to use it only for the  purposes for which we disclose it to them and pursuant to our instructions.

We may also share Personal Data with interested parties in the event that Gradient Labs  Limited anticipates a change in control or the acquisition of all or part of our business or  assets or with interested parties in connection with the licensing of our technology.


If Gradient Labs Limited is sold or makes a sale or transfer, we may, in our sole discretion,  transfer, sell or assign your Personal Data to a third party as part of or in connection with  that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern  

the further use of your Personal Data. In all other situations your data will still remain  protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to  enforce our terms or this Privacy Policy.

5.2 Third-Party Links

This Site may include links to third-party websites, plug-ins and applications. Clicking on  those links or enabling those connections may allow third parties to collect or share data  about you. We do not control these third-party websites and are not responsible for their  privacy statements. When you leave our Site, we encourage you to read the privacy policy  of every website you visit.


We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes  we collected it for. We may retain your Personal Data for a longer period than usual in the event  of a complaint or if we reasonably believe there is a prospect of litigation in respect to our  relationship with you.


You must not use Gradient Labs Limited unless you are aged 16 or older. If you are under 16 and  you access Gradient Labs Limited by lying about your age, you must immediately stop using  Gradient Labs Limited.

This website is not intended for children and we do not knowingly collect data relating to children.


Your information may be stored and processed in the US or other countries or jurisdictions  outside the US where Gradient Labs Limited has facilities. By using Gradient Labs Limited, you  are permitting and consenting to the transfer of information, including Personal Data, outside of  the US.


We keep our Privacy Policy under review and will place any updates here. This version is dated 23  July 2023.

By using Gradient Labs Limited, you consent to the collection and use of data by us as set out in  this Privacy Policy. Continued access or use of Gradient Labs Limited will constitute your express  acceptance of any modifications to this Privacy Policy.


All uses of the word "including" mean "including but not limited to" and the enumerated  examples are not intended to in any way limit the term which they serve to illustrate. Any email  addresses set out in this policy may be used solely for the purpose for which they are stated to  be provided, and any unrelated correspondence will be ignored. Unless otherwise required by

law, we reserve the right to not respond to emails, even if they relate to a legitimate subject  matter for which we have provided an email address. You are more likely to get a reply if your  request or question is polite, reasonable and there is no relatively obvious other way to deal with  or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorised to contract on behalf of Gradient Labs Limited, waive rights or make  representations (whether contractual or otherwise). If anything contained in an email from a  Gradient Labs Limited address contradicts anything in this policy, our terms or any official public  announcement on our website, or is inconsistent with or amounts to a waiver of any Gradient  Labs Limited rights, the email content will be read down to grant precedence to the latter. The  only exception to this is genuine correspondence expressed to be from the Gradient Labs  Limited legal department.